EXECUTIVE SUMMARY

Issues and Actions from 1984 - 1990On January 1, 1984, the state of Missouri implemented a decentralized motor vehicle “Inspection& Maintenance” (I/M) program in the St. Louis metropolitan area (St. Louis City andSt. Charles, St. Louis, and Jefferson counties). This action became necessary due to the federalClean Air Act (CAA) that required states designated as nonattainment to implement either“basic” or “enhanced” vehicle emissions testing I/M programs. The type of programimplemented was determined based upon the severity of the problem and the size of the affectedpopulation. Missouri opted for a “basic” program because it had been designated as “moderate”for ozone nonattainment. The “basic” program was implemented by individual privately ownedvehicle repair shops. The program was jointly administered by the Missouri State HighwayPatrol and the Missouri Department of Natural Resources.The United States Environmental Protection Agency (EPA) conducted its first audit of the I/Mprogram in 1985. The EPA determined that the state’s efforts were not achieving minimumrequired Volatile Organic Compounds (VOC) emission reductions necessary for an acceptableI/M program. EPA conducted a second audit in 1987. Again, the findings reflected that thestate’s efforts were still not meeting sufficient reductions in VOC. The program continued toexhibit low failure rates, an unrepresentative reporting on the tampering rate, and an excessivewaiver rate. These conditions meant that the I/M program was not meeting emission reductionrates required by the Minimum Emission Reduction Requirement (MERR) standards.The two audit findings required that Missouri prepare a corrective action plan (CAP) to correctthe deficiencies. At the time of the audits a single speed idle tailpipe emissions test was beingused which was ineffective for 1981 and newer vehicles. Missouri’s CAP, sent to EPA inDecember 1990, was to implement a BAR90 program. The BAR90 vehicle emissions testingmethod used a computerized analyzer, resulting in more accurate readings.

Issues and Actions from 1991 – 1994The EPA conducted an audit of the new BAR90 program in August of 1992. Once again theEPA determined that Missouri’s efforts were still not meeting sufficient reductions in VOCemissions pursuant to MERR for a basic program. Remedial discussions between EPA andMissouri led to the conclusion that a decentralized BAR90 vehicle emissions testing programwas inadequate for the state’s needs.State’s that fail to meet MERR, even after implementing corrective action plans, are required tosubmit a State Implementation Plan (SIP). The SIP must detail, pursuant to 40 CFR 51.372(a)(1)– (a)(8), how deficiencies will be corrected. These include, but are not limited to: 1)Implementation schedule, 2) Analysis of emission level targets using the most recent EPAmobile source emission model, 3) A description of the geographic coverage of the program,including ZIP codes, 4) Legal authority for the program, and 5) Evidence of adequate fundingand resources to implement all aspects of the program.

These talks culminated in the decision to switch from a decentralized single speed idle tailpipetest to a centralized test-only enhanced test. However, Missouri law did not allow for anenhanced centralized test-only vehicle emissions program. Therefore, the department pursuedlegislation in 1994 to authorize the implementation of an enhanced vehicle emissions testingprogram in the St. Louis nonattainment area.

On May 13, 1994, the legislature passed Senate Bill 590, authorizing a centralized test-onlyenhanced I/M program. The enacting legislation, Sections 643.300 to 643.355, RSMo are knowncollectively as the “Air Quality Attainment Act” and were a direct result of the federal Clean AirAct. The Missouri Air Conservation Commission (MACC) adopted the necessary rules to makethis program a reality. Missouri was required to come into compliance with the air quality healthstandards of the Clean Air Act for ozone by the end of 1996.The deadline was not met and an extension was granted. There were multiple legal challengesbrought by the Missouri General Assembly against the EPA and the State of Missouri regardingthe authority of both the Federal and State government to require such a program. Efforts madeto meet the state legislature’s desires for a hybrid “decentralized” program delayed awarding acontract for more than one year as emission testing vendors failed to submit bids because thegoal of 32 testing stations was not economically feasible for them.

Issues and Actions from 1995 – 1999The Missouri Department of Natural Resources submitted a revised SIP to EPA in 1995. Thisrevision included the 15 percent rate of progress plan (ROP) and the submission of additionaldocumentation in support of the SIP. During this same year the legislature deleted funding forthe I/M program. As a result of that action the EPA on March 18, 1996, informed Missouri thatit was contemplating disapproving Missouri’s I/M SIP because the SIP no longer complied withEPA’s I/M rule.During the 1997 legislative session the Missouri legislature restored funding for the I/Mprogram. The Missouri Department of Natural Resources submitted a revised SIP to EPA onAugust 5, 1997, to reflect that the state was now in compliance with EPA rules regardingadequate tools and resources. As further evidence of compliance with EPA I/M rules the statereleased a Request for Proposal (RFP) October 26, 1998, seeking bidders to implement anenhanced I/M program.In February 1999, a contract was signed with Environmental Systems Products (ESP) to testvehicles in Missouri. ESP is the nation’s largest and most experienced vehicle emissions testingcontractor, testing over 15 million cars a year in North America alone. ESP also operatesinternationally, in countries such as in China and Canada.ESP built 12 new state-of-art vehicle emissions testing stations throughout the nonattainmentarea, including Franklin County. The locations were sought to maximize citizen convenience asdefined by state statute and required in the contract with the State.

Issues and Action from 2000 - PresentThe Gateway Clean Air Program (GCAP) vehicle testing network became operational in April,2000. The affected areas were: St Louis City, St Louis, St. Charles and Jefferson counties, areasdeclared to be “nonattainment” by the EPA, pursuant to the federal Clean Air Act, as amended,42 U.S.C. 7401, et. seq.On opening day, April 5, 2000, GCAP stations tested 1,399 vehicles. ESP also was using “RapidScreen” technology, allowing vehicles to be screened as clean as they are being driven on theroad. This part of the program started in February 2000, and by opening day thousands ofmotorists had received notices stating that their vehicles had passed the emissions test withouthaving to visit a testing station.The state elected to use a two-year IM240 phase-in cut-point method to give the public a chanceto become accustomed to the new test procedure, the method of measuring exhaust emissions

and the repair requirements. As with anything new, there was initial public distrust of the GCAPbecause the motoring public was used to having their local mechanic perform their vehicleemissions test, usually at the same time their vehicle was given a safety inspection.The use of on-board diagnostics (OBD) testing was a part of the original GCAP design. Theoriginal OBD testing design complied with EPA regulations finalized in 1998. These regulationscalled for the use of OBD testing no later than January 1, 2001, for 1996 and newer model yearvehicles. As a result of EPA’s evaluation of various OBD testing and repair issues, EPApromulgated a new OBD rule on April 5, 2001. This rulemaking gave states the option to delayOBD testing until January 1, 2002. It also gave states the flexibility to further postpone OBDtesting until no later than January 1, 2005. Because the GCAP was a relatively new program, thestate decided to take advantage of the additional flexibility offered by the EPA.In March 2002, the MACC held a public hearing regarding Missouri’s OBD testing plan. Theplan called for a one-year delay of OBD testing until January 1, 2003, and a two-year phase-in ofOBD testing until January 1, 2005. In April 2002, the MACC adopted this plan, and thedepartment submitted this plan to the EPA for approval as a SIP revision. In July 2002, theMACC held a public hearing regarding revisions to state rule 10 CSR 10-5.380. This ruleamendment included Missouri’s OBD testing plan adopted in April 2002. In August 2002, theMACC adopted the rule amendment, and the department submitted this rule to the EPA forapproval as an additional SIP revision. Both of these SIP revisions were approved by the EPAon May 12, 2003, the same day that the St. Louis area was redesignated as a maintenance areafor the one-hour ozone standard.

Missouri’s Inspection and Maintenance Program

A. ApplicabilityMotor vehicles subject to Inspection and Maintenance (I/M) emissions inspections reside in theSt. Louis one-hour ozone maintenance area or are primarily operated in this area. Themaintenance area consists of St. Louis City and the Counties of St. Louis, St. Charles, Jefferson,and Franklin.

1. The portion of the St. Louis ozone maintenance area covered by the enhanced I/Melement includes the counties of Jefferson, St. Charles, St. Louis and the City ofSt. Louis. The portion of the St. Louis ozone maintenance area covered by thebasic I/M program is Franklin County.

2. Census Population of the I/M Area

County Population 1990 Population 2000Franklin 80,603 93,807Jefferson 171,380 198,099

St. Charles 212,907 283,883St. Louis 993,529 1,016,315

St. Louis City 396,685 348,189Census information based on U.S. Census Bureau records.Total 1990 census population of the enhanced I/M area: 1,774,501.Total 1990 census population of the basic I/M area: 80,603.Total 2000 census population of the enhanced I/M area: 1,846,486.Total 2000 census population of the basic I/M area: 93,807.

3. A list of zip code areas covered by the I/M program is included in Attachment 10.

B. I/M Legislation and RegulationsThe department is authorized to conduct the enhanced I/M program by statutes passed in 1994.The department has promulgated rules, which specify the requirements for the enhanced I/Mprogram. State statutes and rules have been amended since 1994.

1. The State of Missouri implemented an enhanced motor vehicle I/M program in aportion of the St. Louis ozone nonattainment area starting April 5, 2000. Legalauthority for the program was first provided by the 1994 General Assembly in the“Air Quality Attainment Act” (sections 643.300 - 643.355, RSMo). The Act wasamended in 1998 to allow reformulated gasoline to be sold in the entire St. Louisozone nonattainment area. Section 643.350, RSMo was also amended in 1999 inwhich the $5 wait time penalty was removed. A copy of this act is included inthis document as Attachment 1.

A copy of the Missouri rule (10 CSR 10-5.380) which specifies the details ofMissouri’s enhanced I/M program is included in Attachment 2. The rule wasamended in 1999 to include a clean screen program, two-speed idle cut-points andOn-Board Diagnostics (OBD) evaluation requirements.Additionally, an emergency rule amendment was filed on November 30, 1999,effective January 1, 2000, that allowed for a transitional period for an emissionextension sticker that temporarily delayed the emission inspection requirement forup to six months. This was necessary because the vehicle emissions testingprogram did not start until April 5, 2000, which meant that even model yearvehicles, whose registration expired in January, February or March 2000, wereunable to be emissions tested. The follow-up rule amendment, whichincorporated the changes contained in the emergency rule, was filedDecember 1, 1999, with an effective date of July 30, 2000. This amendment alsoeliminated the $5 wait time penalty. Additionally, this rule allowed for FranklinCounty residents to have their vehicles biennially tested by bringing their vehiclesto any of the stations in the enhanced area.The most current rule amendment was filed May 15, 2002, with an effective dateof December 30, 2002. The substantive part of the rule increased the waiveramount for 1971 to 1980 model year vehicles from $75 to $200. Model year carsafter 1980 must spend a minimum of $450 to receive a waiver. Before any modelyear car can receive a waiver, in addition to spending the required minimumrepair amount, must show a decrease in the failing pollutant(s), while not failingin another pollutant(s), after repair. OBD II pass/fail testing becomes mandatoryin January 2005, for 1996 and newer vehicles. This amendment also initiated theOBD II phase-in starting in January 2003, for 1996 and newer vehicles. DuringOBD II phase-in, 1996 and newer vehicles which fail the OBD II test can betested using the IM240 method. If the vehicle fails that test, the owner has theoption to either repair it to OBD II standards or IM240 standards.

The contract for operating the I/M program requires that forty percent (40%) ofthe motor vehicles be exempted from a station based test. This includes thestatutory exemption for the most recent two model years, which varies with modelyears and is usually in the range of twelve percent (12%). The first two (2) modelyear vehicles do not have to pay an emission fee. At least twenty percent (20%)of the motor vehicles must be exempted using RapidScreen remote sensing cleanscreening methods. The remainder, or about eight percent (8%), may beexempted through the use of additional model year exemptions, moreRapidScreen remote sensing exemptions or a hybrid exemption method usingboth RapidScreen and a low emitter indexing system. Any motor vehicle that isexempted using one of the RapidScreen clean screen methods will have to pay anemission fee in order to receive a clean screen certificate that will be needed formotor vehicle registration.

2. The State of Missouri has implemented a basic motor vehicle I/M program inFranklin County. Section 307.366, RSMo provides the legal authority for thisbasic I/M program. The statute was amended in 1999 to give the residents of

Franklin County the option of an annual basic emission or biennial enhancedemission inspection test and registration cycle. A copy of this statute is includedin this document along with the enhanced I/M statutes as Attachment 1. A copyof the Missouri rules (11 CSR 50-2 and 10 CSR10-5.375) which specify the 1999changes to Missouri's basic I/M program is included as Attachment 2B.

3. State regulations specify that the geographic boundaries of the program in eachcounty of the nonattainment area are countywide.

C. I/M Performance Standard for the Enhanced and Basic ProgramThe department uses the EPA approved models to evaluate the I/M program described herein foremission reduction effectiveness.

1. Attachment 6 contains the input and output files for MOBILE6. This model wasused to estimate the emission reduction benefits of implementing an enhancedI/M program in the St. Louis nonattainment area.

2. The enhanced I/M program will meet or exceed the enhanced I/M performancestandard beyond the year 2002. After the complete implementation of allprogram elements, the Missouri Department of Natural Resources (MDNR) willdemonstrate that the program meets the relevant performance standards.Additionally, the I/M program design criteria will be documented relative to theperformance standards.

3. Attachment 7 includes a description of the calculations used for the modeling.

D. Network Type and Program EvaluationBoth St. Louis ozone nonattainment area I/M programs are contractor operated. The emissiontest stations are operated by a single contractor, Environmental Systems Products (ESP) MissouriInc. The contractor only conducts emission tests. No repairs or diagnosing of motor vehicles areallowed at the emission test stations.

1. The enhanced I/M program is a centralized, test-only centralized, test-only systemoperated by the State’s contractor, ESP Missouri Inc. Vehicles in St. Louis City,and the counties of St. Louis, St. Charles and Jefferson included in the emissionreduction demonstration discussed in section C and required to comply with theI/M program are tested biennially by the contractor at centralized test-only I/Memission test stations. The contract specifies, as does state law, that the emissiontest stations shall be test-only emission test and shall not offer motor vehicleemissions repairs, parts or services of any kind. No person operating or employedby an emissions inspection station shall repair, diagnose or maintain motorvehicle emission systems or pollution control devices for compensation of anykind (section 643.310, RSMo).

2. The basic I/M program is a centralized, test-only system. Vehicles in FranklinCounty are included in the emission reduction demonstration discussed in sectionC and required to comply with the I/M program are tested annually by the

contractor at centralized test-only I/M emission test stations. The contractspecifies that the emission test stations shall be test-only and shall not offer motorvehicle emissions repairs, parts or services of any kind. No person operating oremployed by an emissions inspection station shall repair, diagnose or maintainmotor vehicle emission systems or pollution control devices for compensation ofany kind.Per section 307.366 RSMo, the residents of Franklin County have the option toget either a basic, annual emission test or an enhanced biennial emission test. If aresident decides to opt for an enhanced biennial emission test they must take thevehicle to one of the four counties where the enhanced I/M program is beingoperated.

3. MDNR has developed an evaluation methodology consistent with the EPAregulations. The procedures includes the following steps:a. MDNR representatives overtly visit each I/M emission inspection lane, at

least twice per year. They audit the test lane components, the mechanical,such as the dynamometer, the analytical, such as the laboratory grade gasspectrographs, and the electronic, such as the On-Board Diagnosticconnection connector. They audit the record keeping and observeinspectors performing the emission tests on vehicles submitted for testingby the general public.

b. MDNR representatives covertly audit each I/M station inspector at leastonce per year. Every month of the year there are covert audits. Vehiclesare chosen randomly and are tested at different times during the day.During covert audits, MDNR staff not only check for adherence to testpractices and procedural requirements by the contractor, but also recordthe results of the observation and emission inspection.

c. The program evaluation report uses the MOBILE 6 model to compare theGCAP with the Basic I/M Performance Standard (the requirement formoderate ozone nonattainment areas) and the Enhanced I/M PerformanceStandard (the design goal of the GCAP). The program evaluation reportalso converts all station and clean screening data into full-length IM240test data and then calculates the aggregate fleet reductions over a two-yeartest cycle. This report provides EPA, the General Assembly, and thepublic with an accurate evaluation of the benefits of the GCAP, and anevaluation of its contribution to St. Louis air quality improvements.

4. The results of the ongoing quality assurance program and the program evaluationsare incorporated into the annual report. The annual report will meet therequirements of 40 CFR 51.366, described in Section Q. The first annual reportwas submitted to EPA two (2) years after the date of program implementation,with subsequent annual reports submitted July 1, of each subsequent calendaryear.

E. Adequate Tools and ResourcesThe contractor and state expenses are recovered with test fees, or the fee to motorists for the I/Minspection. The state’s portion of the fee is appropriated by the Missouri General Assembly for

state costs for I/M oversight staff and their workspace and equipment.

1. The Enhanced Test I/M Program is funded through a per vehicle inspection feeauthorized by the General Assembly. The fee is $24 as set by the Missouri AirConservation Commission (section 643.350, RSMo 1998). The inspection fee isreduced for motorists who wait longer than thirty (30) minutes before theinspection begins (subsection 1 of section 643.350, RSMo Supp. 1998). SeeAttachment 4, the contract language, for the wait time penalty fee reductionbreakdown. The contractor is required by contract to remit $2.50 per motorvehicle inspection fee collected, to a State Treasurers’ account on a weekly basisas established by the Air Conservation Commission (10 CSR 10-5.380). TheDirector of Revenue deposits the fees received in the state treasury to the credit ofthe “Missouri Air Emission Reduction Fund.” Moneys in the fund are, subject toappropriation and expended for the administration and enforcement of the “AirQuality Attainment Act” by MDNR (subsection 5 of section 643.350, RSMo).

2. The Basic Test I/M Program is funded through a per vehicle inspection feeauthorized by the General Assembly. The fee cap has been set by statute at$10.50 for each basic emission inspection performed. The contractor is requiredby law to remit $0.75 of the per motor vehicle fee to a State Treasurer's accountwithin the time period established. The State’s portion of the fee is deposited inthe “Missouri Air Pollution Control Fund.” Moneys in the fund are subject toappropriation and expended for the administration and enforcement of the basicI/M program in Franklin County by MDNR.

3. Attachment 5 includes a copy of a portion of House Bill 6 (Budget Bill) showingI/M program appropriations for state fiscal year 2000 and a budget for theprogram. MDNR will maintain I/M staffing levels to adequately cover overt andcovert auditing, data collection and analysis, report preparation, performancemonitoring, technical assistance, consumer assistance, waiver oversight,administrative and clerical functions. The Personnel Service Summary tablelocated on the following page outlines the positions allocated for the I/Mprogram.

4. MDNR has a budget for vehicles to be used for covert auditing; MDNR alsomaintains a rotating fleet of other department vehicles to maintain covertoperation integrity. The MDNR budget also specifies the supply of necessaryequipment and calibration pollutant(s) to be used in the quality control audits.The contractor supplies all other equipment or equivalent services, including butnot limited to test equipment, test facilities, and computer equipment capable ofdata processing, analysis, and reporting. MDNR has complete access to thecontractor’s computer system to allow MDNR staff to analyze data and conductother necessary data related functions. See Attachment 4 of the contract forspecifics.

Personal Service Summary

Environmental Specialist IV 2.0 FTE Chief for I/M unit. Supervises all APCP I/M staff and field staff.

Environmental Specialist III 1.0 FTE Supervision of technical positions, technical assistance andconsumer education/assistance.

Environmental Specialist I/II 8.0 FTE Overt and covert station audits, performance monitoring, technicalassistance, and consumer education/assistance and waiveroversight.

Computer Information TechnologySpecialist

1.0 FTE Technical support for hardware and software dedicated to I/M,database development, general DP management of dedicated I/Mdata system.

Management Analyst I 1.0 FTE Recording, tracking and analyzing fee revenues and expenditures,budget and sub-grant development/tracking.

Motor Vehicle Mechanic 2.0 FTE Preparing vehicles for covert audits and conducting covert audits ofvehicle repair facilities.

Environmental Engineer I/II 1.0 FTE Check equipment specifications for the contract/operation oversight

Planner II 1.0 FTE Contract development, oversight data, and fiscal control.

Clerk Typist II 2.0 FTE Clerical support for technical staff, management, and researchanalysts.

Public Information Specialist I 1.0 FTE Coordinate public information strategies and implementationbetween the contractor(s) and the state.

Environmental Engineer III 1.0 FTE Supervise the field staff who will do the field audits of emissiontest stations and repair facilities.

TOTAL 21.0 FTE

F. Test Frequency and ConvenienceEnhanced emissions I/M tests are required biennially. Basic emissions tests performed inFranklin County are required annually, although Franklin County residents have the option tochoose test type and frequency as previously detailed. Motorist convenience is assured by bothstate law and the contract provision regarding station accessibility, clean screening, and the waittime penalty that applies to the enhanced I/M stations.

1. Enhanced Test I/M Program

Test frequency is biennial for all subject vehicles in the enhanced test area. Fornew vehicles, which have an odometer reading of less than six thousand miles atthe time of original sale, the model year dictates when the first emissionsinspection is required. For even (odd) model year new vehicles originally sold inan even (odd) calendar year, the first emissions inspection is required for thesecond registration renewal which corresponds to two years after initial titling andregistration. For even (odd) model year new vehicles originally sold in an odd(even) calendar year, the first emissions inspection is required for the firstregistration renewal which corresponds to three years after initial titling andregistration.For example, if a 2000 model year vehicle is sold in 1999, the first emissionsinspection is required for re-registration in the calendar year 2002. This provisionfacilitates the implementation that even model year vehicles will be tested in evencalendar years and odd model year vehicles will be tested in odd calendar years,and biennially thereafter (subsection 1 of section 643.315, RSMo and 10 CSR10-5.380).Newly purchased used vehicles or those requiring a title transfer are required tobe emission inspected and certified prior to being registered in a new owner’sname. Thereafter, they are required to be inspected biennially such that evenmodel year vehicles will be tested in even calendar years and odd model yearvehicles will be tested in odd calendar years. Statutory and regulatory authority iscontained in sections 643.300 to 643.355, RSMo (Attachment 1) and 10 CSR 10-5.380 (Attachment 2).Vehicles that are newly registered in the program area from other states or fromother parts of the state must be inspected according to the odd-odd or even-evencycle.

2. Basic Test I/M ProgramEmission testing frequency may be either annual or biennial for any subjectvehicle in the basic test I/M program. The residents of Franklin County maychoose either inspection cycle. If they choose the biennial cycle, they must havetheir motor vehicle inspected in a inspection station located in Jefferson,St. Charles, St. Louis County or St. Louis City and then are subject to inspectionrequirements of those counties.

3. The contract language in Attachment 4 and the statute in Attachment 1 containprovisions relating to motorist convenience that specify the location of enhancedI/M stations and waiting times for motorists at enhanced I/M stations. Thelocations are determined on the basis of proximity to the largest number ofmotorists possible. Provisions in the enhanced test program provide a monetaryreduction of the inspection fee for exceedance of maximum waiting times bypatrons. Standard hours of operation are set based on the contract as per languagein Attachment 4. The enhanced I/M program operates a minimum of sixty-six(66) hours per week, Monday through Saturday, as required by law. The basicI/M program operates at least forty (40) hours per week, as required by law.

G. Vehicle Fleet CoverageSubject vehicles or motor vehicles that are subject to the emission test program are motorvehicles that are domiciled or primarily operated in the St. Louis ozone nonattainment area;including those that are part of private or governmental fleets; all gasoline-fueled light dutyvehicles except motorcycles (cars, pickup trucks, vans, sport utility vehicles) of model years1971 and newer. Vehicles over 8,500 pounds gross vehicle weight rating, vehicles of the latesttwo (2) model years, and vehicles fueled exclusively with diesel fuel, propane, naturalpollutant(s), electricity or other alternate fuels are exempt from emission inspectionrequirements.

1. Enhanced Test I/M Programa. All 1971 and later model year gasoline powered light duty vehicles and

light duty trucks up to eight thousand five hundred pounds (8,500 lbs.)Gross Vehicle Weight Rating (GVWR) are subject to the program. Tablesshowing the total number of subject vehicles in each county sorted bymodel year (as of February 2003) are included in Attachment 8a. Thesefigures reflect the actual number of gasoline powered cars, trucks, RVs,and buses under eight thousand five hundred and one pounds (8,501 lbs.)GVWR registered (titled and registered or registered only) in the enhancedI/M area. The total number to be tested is estimated to be 1.3 million.This information is based on the Missouri Department of Revenue(MDOR) records.

b. Dual-fueled vehicles are required to be tested using their gasoline cycleonly and must meet the same test requirements and quality controlstandards as all subject vehicles. Vehicles with an exchanged engine (anengine not originally designed for the vehicle) are tested according to theemission standards applicable to the model year of the vehicle body. Tothe extent possible, all pollution control equipment required for the vehiclemodel year and the original engine must be in place and functional.Vehicles registered as specially constructed are tested using a single speedidle test. Vehicles that cannot safely be transient tested (i.e. short wheelbase 4WD vehicles) are tested using a two speed idle test.

c. The following vehicles are exempt from the inspection requirements of theI/M program (reference subsection 3 of section 643.315, RSMo): (1)Motor vehicles with a manufacturer's GVWR in excess of eight thousandfive hundred pounds (8,500 lbs.); (2) Motorcycles and motor tricycles; (3)Model year vehicles prior to 1971; (4) Vehicles which are poweredexclusively by electric or hydrogen power or by fuels other than gasoline;(5) Motor vehicles registered in an area subject to the inspectionrequirements of sections 643.300 to 643.355 which are domiciled andoperated exclusively in an area of the state not subject to the inspectionrequirements of sections 643.300 to 643.355, but only if the owner of suchvehicle presents to the department an affidavit that the vehicle will beoperated exclusively in an area of the state not subject to the inspectionrequirements of sections 643.300 to 643.355 for the next twenty-four

months, and the owner applies for and receives a waiver which shall bepresented at the time of registration or registration renewal; and (6) Newand unused motor vehicles, of model years of the current calendar yearand of any calendar year within two years of such calendar year, whichhave an odometer reading of less than six thousand miles at the time oforiginal sale by a motor vehicle manufacturer or licensed motor vehicledealer to the first user. Vehicles meeting the above criteria will beidentified as exempt by running queries of the MDOR motor vehicleregistration database. Tables showing the total number of exempt vehiclesin each county in each model year (as of February 2003) are included inAttachment 8b.

2. Basic Test I/M Programa. All 1971 and later model year gasoline powered light duty vehicles and

light duty trucks up to eight thousand five hundred pounds (8,500 lbs.)GVWR are subject to the program.

b. The following vehicles are exempt from the inspection requirements of theI/M program (reference subsection 2 of section 307.366, RSMo): (1)Motor vehicles with a manufacturer's GVWR in excess of eight thousandfive hundred pounds (8,500 lbs.); (2) Motorcycles and motor tricycles; (3)Model year vehicles prior to 1971; (4) School buses; (5) Diesel-poweredvehicles; (6) Motor vehicles registered in the area by this section butwhich are based and operated exclusively in an area of this state notsubject to the provisions of this section if the owner of such vehiclepresents to the director of revenue a sworn affidavit that the vehicle willbe based and operated outside the covered area; and (7) new motorvehicles not previously titled or registered prior to the initial motor vehicleregistration or the next succeeding registration which is required by law.

3. MDNR works closely with private and public fleets that operate vehicles in theI/M area to ensure these vehicles are emissions tested. Arrangements have beenmade for these fleets to provide MDNR with a list of vehicles operated in the areaand to update that list on a quarterly basis. All subject vehicles owned by federal,state, and local governmental entities are emissions inspected in accordance with10 CSR 10-5.380 and 11CSR 50-2.400.Attachment 8c lists the number of fleet vehicles subject to emissions testing.MDNR continues to explore ways to identify other vehicles operated in but notregistered in the I/M area. Strategies used to identify unregistered vehiclesoperating in the I/M area are listed in Section L.

4. Private and local government fleets are required to be tested at official test-onlyemission test stations. The contractor gives special consideration to fleets of ten(10) or more vehicles with policies such as special hours and payment vouchersper regulatory and contract language. Some fleets may opt to have I/M testingequipment installed at a fleet testing facility that will be operated and maintainedby the contractor at the fleet owner's expense (and connected to the on-line data

system). Mobile IM240 test equipment may also be used at these facilitiesconnected by modem to the on-line computer system. The same test procedures,equivalent equipment, and the same quality control procedures will be used inthese fleet facilities as at the official test stations. The same quality assuranceprocedures will be used to ensure adequate operation of these fleet facilitiesbecause the fleet facilities are operated and maintained by the contractor andaudited the same as the official test stations. Currently, no fleet has opted for thismethod.

5. Federal fleet vehicles are required to comply with the same inspection programrequirements as other fleet vehicles in the enhanced I/M area. There areapproximately fifteen (15) Federal agencies in the State of Missouri I/M area,with a total of approximately two thousand six hundred (2,600) Federal fleetvehicles, including United States military vehicles and United States PostalService vehicles in the State of Missouri I/M area. As required by EPA guidance,the I/M rule requires that vehicles which are operated on federal installationslocated within an I/M program area are to comply with the vehicle emissionsinspection requirement, regardless of whether the vehicles are registered in theI/M area. This rule applies to all employee-owned and leased vehicles and allvehicles owned by civilian and military personnel on federal installations as wellas agency-owned or operated vehicles, except tactical military vehicles. MDNRworks cooperatively with all government organizations to ensure that vehicles areemissions tested.

H. Test Procedures and StandardsFor 1971 – 1980 model years subject vehicles, the enhanced emissions test consists of a singlespeed idle test. For 1981 and newer model year subject vehicles, the enhanced emissions testconsists of an IM240 transient test, an OBDII fault code check and gas cap integrity test forsubject vehicles of model year 1981 and newer. If for defined reasons a 1996 or newer vehiclecannot be OBDII tested or fails the test using OBDII test equipment, then an IM240 transient testis required to be performed. If for technical reasons a vehicle fails an IM240 transient test, thena two (2) speed idle test is required. IM240 test procedures allow for “fast pass” in order to savetime, but also allow for an immediate complete retest upon failures that are within two times theemission limit to mitigate false failures. The first IM240 test data is ignored, and the test istreated as a pre-conditioning run. Test procedures are specified in the contract at RFP section 6and Method of Performance section 10.7.5.g.

The basic inspection used in Franklin County for all 1971 and newer model year subject vehiclesis a single speed idle test, an OBDII advisory check for 1996 and newer model year vehicles, anda pollutant(s) cap integrity test for all 1981 and newer model year vehicles.

Upon failure of the emission inspection, vehicle emission components are visually inspected fortampering. After repairs, vehicles must be re-tested and meet the program requirementsestablished for achieving a “Pass” or a “Waiver” regarding the emission test results.The contractor clean screen a large percentage of the subject vehicles. A majority of the subjectvehicles are clean screened using Remote Sensing Devices (RSD). A vehicle must be screenedon the road as “clean” two (2) times on two different days within a twelve (12) month period

prior to the license plate expiration month and year in order to be exempted from emissioninspection station. Sites for placement of the roadside devices follow EPA guidance forplacement for parameters such as road grade, single lane traffic, and high likelihood that vehiclesare at operating temperature. Requirements are in the contract at RFP 4.10.2 and Method ofPerformance 10.7.5.o. Remote sensing cutpoints used are established in 10 CSR 10-5.380.Cutpoints are the numeric values of the emission levels used to determine the clean status of avehicle, as compared to the measured emission test results. The contractor is striving to meet thetotal exemption goal of forty percent (40%) using a combination of model year exemption (firsttwo model years) and RSD clean screening.

1. The authority to establish I/M test procedures and standards is contained in theenabling legislation in Attachment 1. The test procedures and test standards arespecified in the rule in Attachment 2A &2B.

2. Enhanced Test I/M Programa. All 1971 through 1980 subject vehicles are subject to an idle test. All

1981 and newer subject vehicles are subject to IM240 transient emissiontesting. All vehicles are subject to an evaporative integrity system testconsisting of a pollutant(s) cap test. All 1996 and newer model yearsubject vehicles were subject to an OBD fault code check on an advisorybasis until December 31, 2002. Vehicle test results tied to readings fromthe OBD system started January 1, 2003. During the OBD phase-inperiod, vehicles that pass the OBD test are exempt from the IM240 test.Vehicles that fail the OBD test but pass the IM240 test do not have to berepaired this test cycle. Vehicles that fail the OBD and IM240 test mustbe repaired and re-tested. Commencing January 1, 2005, vehicles shallfail the OBD test if they fail to meet the requirements of 40 CFR 85.2207.The IM240 test includes fast-pass test algorithms. Also, vehicles failingthe IM240 test within two times the cutpoints are immediately retested.The retest is to mitigate the false failures due to inadequate engineconditioning (warm up).

b. Vehicles subject to the IM240 test must meet the cutpoints set forHydrocarbons (HC), Carbon Monoxide (CO), and Nitrogen Oxides (NOx)in order to pass the test. Emission limits, or cutpoints, are stipulated in therule 10 CSR 10-5.380, including a phase-in set of cutpoints. The phase-inIM240 cutpoints were in effect for the first two (2) years of the enhancedI/M program. Starting February 4, 2002, final IM240 cutpoints wereimplemented. Those vehicles subject to the single speed or two speed idletests must meet the cutpoints set for both HC and CO. All vehicles failingany part of the initial test are visually inspected to ensure the presence ofall emission control or related equipment (anti-tampering). All vehiclesfailing any part of the initial test must pass a reinspection and anequipment check after the failing portion of the vehicle's emission controlsystem has been repaired. Vehicles failing an initial tailpipe emissions testfor any pollutant must pass a retest for all pollutants in order to receive acertificate of compliance. Vehicles being retested for failure of the

pollutant(s) cap integrity test are also required to pass a tailpipe emissionsre-test.

c. The rule in Attachment 2 and the contract language in Attachment 4specify that each test station shall have one (1) or more areas wheremotorists may view the inspections of their vehicles in their entirety. Therule and contract also specify that vehicles shall be rejected for unsafeconditions, including exhaust leaks, fluid leaks, tires with visible cords, orother conditions determined to be unsafe by the contractor or thedepartment.

d. Along with start-up and the two year phase-in cutpoints the departmentbegan the program with a voluntary testing program which encouraged thepublic to have their vehicles tested by the enhanced I/M test methodbefore it was mandatory. This is a requirement for the contractor and isdetailed in Attachment 4.

3. Basic Test I/M Programa. All 1971 and newer subject vehicles are subject to single speed idle

testing, as well as evaporative system integrity testing, in the form of apollutant(s) cap test. All 1996 and newer model year subject vehicles aresubject to an advisory OBDII diagnostic code check.

b. Those vehicles subject to the single speed idle test must meet the cutpointsset for both HC and CO. All vehicles failing any part of the initial test arevisually inspected to ensure the presence of all emission control or relatedequipment (anti-tampering). All vehicles failing any part of the initial testmust pass a reinspection and an equipment check after the failing portionof the vehicle's emission control system has been repaired. Vehiclesfailing an initial tailpipe emissions test for any pollutant must pass a retestfor all pollutants in order to receive a certificate of compliance. Vehiclesbeing retested for failure of the pollutant(s) cap integrity test are requiredto pass a tailpipe emissions test.

c. The rule and contract specify that vehicles shall be rejected for unsafeconditions, including exhaust leaks, fluid leaks, tires with visible cords, orother conditions determined to be unsafe by the contractor or thedepartment.

4. Both inspection programs have a clean screening element. The contractorprovides a clean screen program that exempts forty percent (40%) of the subjectmotor vehicles from the centralized emission test stations. The contractor usesthe remote sensing devices to clean screen at least twenty percent (20%) of thesubject motor vehicles. Low-emission profiling, remote sensing devices, ormodel year exemptions may cover the remaining twenty percent (20%). Missouristatute requires that the newest two model years are exempt from any emissioninspection requirements. Only motor vehicles of the newest two model years areexempt from the emission inspection fee. The contractor may use one method ora combination of the aforementioned methods to exempt a total of forty percent(40%) of the subject fleet.

I. Test EquipmentThis section describes the test equipment that the contractor uses in the I/M stations. Theenhanced I/M program primarily uses the IM240 transient test, which means the vehicles aredriven on a dynamometer (set of rollers), which could be described as a vehicle treadmill. Thevehicle is idled, accelerated, and decelerated during the IM240 test using a protocol per the EPAguidance. The accelerating and decelerating of a motor vehicle simulates real world drivingconditions. Vehicles that for technical reasons cannot be tested with IM240 and vehicles inFranklin County are tested with non-transient tests, or tests done without the wheels turning on adynamometer. The department adheres to the EPA guidance and recommendations forequipment. Contract requirements for equipment are in the RFP section 5 and Facilities section10.5.1.e.

1. Test equipment specifications, included in the contract, are based on thespecifications in the EPA's Title 40, Part 51, Subpart S, Appendix D and theIM240 & Evap Technical Guidance (April 2000), 40 CFR 85.2226 and 85.2227.

2. Enhanced Test I/M Programa. Each test lane is equipped with the following equipment for the IM240: a

dynamometer, Constant Volume Sampler (CVS), a flame ionizationdetector for HC measurement, two (2) Non-Dispersive Infrared (NDIR)analyzers for CO measurements (one (1) low range and one (1) highrange), one (1) NDIR analyzer for Carbon Dioxide (CO2) measurement,and one (1) chemiluminescent analyzer for measuring NOx. Each lanealso has the necessary equipment to safely restrain the vehicle and cool thevehicle engine during the IM240testing.

b. The same test analyzers are capable of being adjusted to basic idle testingspecifications in order to conduct the idle test. Each test lane alsocontains: any equipment necessary to pressurize the pollutant(s) cap andtest it for leaks according to the standards stated in 10 CSR 10-5.380 andthe equipment necessary to interrogate vehicle OBD systems in all 1996and newer model year subject motor vehicles.

c. All test equipment and processes are automated to the highest degreepossible. All computerized equipment has lockout features to preventtampering by unauthorized personnel. Station managers, or theirsupervisors, have authorization to clear lock-outs or access the hardwarefor any purpose other than to perform an emissions test and are required toenter an access code that identifies them personally in order to do so. Thedate and reason for all lockouts and by whom lockouts are cleared are keptin a data file. Data entry functions associated with the test are streamlinedthrough the use of reference tables and bar coded scanners of VehicleIdentification Numbers (VIN) and other features so that manual data entryis minimized.

d. The testing process is almost completely computer controlled. Theprocess begins with data entry, which involves entering the vehicle make,model, model year, license plate number, and three digits of the VIN. Theinspector obtains the VIN digits from the vehicle itself and checks the

license plate number as well. The entry calls up a preexisting file basedon the registration database and previous inspections on the vehicle. Theinspector compares the data in the file and confirms that the vehiclepresented matches the VIN/license plate combination in the file. Afterverification, the inspector takes control of the vehicle. Preconditioning isperformed if necessary. Once the equipment is in place, the test isinitiated. The test process from that point is completely automatic,including the pass/fail decision and test procedure. Test lanes are linkedon a real-time basis to a central computer; test data is recorded onto acentral data base at the time a test is completed and multiple initial testingis prevented. Records are kept in the central database for three (3) yearsbefore being downloaded for storage. System lockouts are initiatedwhenever the following quality control checks are failed or not conductedon schedule: periodic calibration or leak checks, CVS flow rate check,dynamometer coast-down, roll speed and roll distance check, inertiaweight selection check, and pollutant(s) cap equipment check. Allelectronic calibration and system integrity checks are performedautomatically, i.e., without specific prompting by the inspector prior toeach test, and quality control is be under computer control to the greatestextent possible.

2. Basic Test I/Ma. Each test lane is equipped with the following equipment for the idle test:

one (1) detector for HC measurement, two (2) NDIR analyzers for COmeasurements (one (1) low range and one (1) high range), and one (1)NDIR analyzer for CO2 measurement. Each test lane is also equippedwith: the equipment necessary to pressurize the pollutant(s) cap and test itfor leaks according to the standards to be stated in 11 CSR 50-2.400, andthe equipment necessary to interrogate vehicle OBD systems in all 1996and newer model year subject motor vehicles.

b. All test equipment and processes are automated to the highest degreepossible. All computerized equipment has lockout features to preventtampering by unauthorized personnel. Station managers, or theirsupervisors, have authorization to clear lock-outs or access the hardwarefor any purpose other than to perform an emissions test and are required toenter an access code that identifies them personally in order to do so. Thedate and reason for all lockouts and by whom lockouts are cleared are keptin a data file. Data entry functions associated with the test are streamlinedthrough the use of reference tables, bar code scanners of VIN, and otherfeatures so that manual data entry is minimized.

c. The testing process is almost completely computer controlled. Theprocess begins with the lane inspector entering the vehicle’s license platein the computer. If information is provided, the inspector verifies the last4 digits of the vehicle’s Vehicle Identification Number (VIN) with theinformation on the computer screen. If not correct, the lane inspector willenter the VIN from the vehicle. If vehicle information is brought up onthe computer screen, the inspector will change any incorrect data, or enter

the last 4 digits of the VIN for a vehicle without a license plate. If there isno vehicle information at all on the computer screen, the lane inspectorwill enter make, model, model year, vehicle class, gross vehicle weightand engine type and size in the computer. After any of these processes hasbeen completed, the inspector takes control of the vehicle. A test of thegas cap may be demanded if the vehicle is a 1981 or newer. Moving thevehicle to the emission testing area, the appropriate test process asdescribed earlier is initiated and performed. Once the equipment is inplace, the test is initiated. The test process from that point is completelyautomatic, including the pass/fail decision and test procedure. Test lanesare linked on a real-time basis to a central computer; test data are recordedonto a central data base at the time a test is completed and multiple initialtesting is prevented. Records are kept in the central database for threeyears before being downloaded for storage. System lockouts are initiatedwhenever the following quality control checks are failed or not conductedon schedule: periodic calibration or leak checks and pollutant(s) capequipment check. All electronic calibration and system integrity checksare performed automatically, i.e., without specific prompting by theinspector prior to each test, and quality control is under computer controlto the greatest extent possible.

J. Quality ControlEmission test equipment is calibrated using guidelines set in Title 40, part 51, subpart S.Appendix A and in IM240 Evap Technical Guidance 40 CFR 85.2234 and 85.2235, which is inthe RFP in attachment 4. The equipment and other facilities are also maintained on a setschedule, to preclude as much as possible delays, inaccuracies, or inconveniences to the publicdue to malfunctions.To assure quality control of equipment and facilities, the department oversees compliance tocontract requirements for quality control. The contract, at RFP section 5.6 and at Method ofPerformance 10.7.5.r., outlines requirements for quality control and maintenance, includingweekly and monthly reports.

1. These measures ensure that Missouri meets its commitment to provide motoristswith consistent and accurate test results.

2. Attachment 9- Part A contains the manual of quality control and periodicmaintenance procedures followed by inspection site personnel to ensure that allequipment is properly calibrated. This manual also includes the calibration andmaintenance schedules to be followed at all test sites.

3. Attachment 9- Part B contains the record keeping and document securityprocedures to be followed at all test sites and other locations involved in thedistribution and processing of program documents. Responsible agents areidentified and accountability is assessed for each step of the process. Alsoincluded is a description of how documents are to be tracked, via controlnumbers, throughout all phases of the process from initial production, throughdistribution, issuance, and registration.

3. Attachment 9- Part C contains the specifications to be used for all testingequipment approved for use in the I/M program. These specifications include

minimum durability and functional requirements to ensure accurate measurement,processing, and recording of test samples under a wide range of adverse ambientconditions.

K. Waivers and Compliance Using Diagnostic InspectionCompliance Waiver 10 CSR 10-5.380(3)(I)1-5: Compliance waivers are issued for motorvehicles that cannot pass the emission inspection, provided a minimum dollar amount was spentfor repairs in an effort to lower emissions to within the state limits. Per the contract, RFP section6.9, repairs are visually checked to verify that repairs were actually done and that they wereapplicable to the failure.

Repair records must show that repair expenditures were not covered by either a recall ormanufacturer warranty and that parts costs and labor costs of recognized technicians total theminimum applicable amount for the model year of the vehicle.

These visual observations of the vehicle and the receipt analysis that lead to a waiver decision isconducted by station management (not by the lane inspectors that conducted the initial orsubsequent inspections on the vehicle in question) per the contract at RFP section 6.9.1 andMethod of Performance section 10.7.5.g.9.2. Station managers are specially trained on vehicleemission devices and the waivers. State staff may also occasionally issue waivers at either theI/M stations or at the state’s quality assurance facility. These occasions would in most casescoincide with motorists’ complaints about the contractor’s inspection or waiver actions. Becausevehicle emission devices vary by make and model, the station managers have lists, or locationdescriptions, regarding the waiver procedure in either paper form or on computer software.Out of Area Waiver – 10 CSR 10-5.380(3)(I)6: Out of Area Waivers are issued for motorvehicles that are registered in a city or county in which an emissions inspection is required butthe vehicle is operated exclusively out of the area. The vehicle owner must present a completed,signed waiver affidavit to the department that says the motor vehicle will be operated exclusivelyoutside the counties of Jefferson, St. Charles, St. Louis, or the City of St. Louis for at least thenext twenty-four (24) consecutive months from the time of registration for which the waiver isissued. The emissions inspection compliance certificate has an indicator showing that thevehicle received an out of area waiver. The vehicle owner is then issued a windshield sticker forthe vehicle.Reciprocity Waiver – 10 CSR 5.380(3)(I)7: The department has not entered into any reciprocityagreements.

1. Enhanced Test I/M Programa. A waiver rate of eight percent (8%) of failed vehicles is assumed in the

MOBILE modeling that demonstrates that the I/M program meets theapplicable performance standard. The State of Missouri maintains awaiver rate that in practice is equal to or lower than eight percent (8%).Auditors and waiver issuance personnel monitor waivers via trackingnumbers. If the waiver rate reported in the annual report to EPA is higherthan 8%, the State will attempt corrective action to lower the waiver rate.If the waiver rate cannot be lowered to levels committed to in the SIP, or ifthe State chooses not to implement measures to do so, then the State willrevise the I/M emission reduction projections in the SIP and will

implement other program changes needed to ensure the performancestandard is met.

b. The State of Missouri issues waivers only when the requirements of theattached I/M rule and this paragraph are met. In the enhanced I/M area,inspection station management are responsible for issuing waivers.Waiver issuance personnel review repair receipts to verify that a minimumexpenditure equal to or greater than $200 for 1971 through 1980 modelyear vehicles, $450 for 1981 and later has been made; verify that onlyrepairs appropriate to the cause of the test failure have been claimed;inspecting the vehicle; and verify the vehicle has shown an improvementin exhaust emissions since the initial test. Waiver issuance personnel willalso check the emissions test report for the odometer reading and modelyear and determine if the vehicle is eligible for warranty repairs, and willrequire written denial of warranty coverage before issuing a waiver for avehicle that is eligible for such repairs. Labor costs are not eligibletowards the minimum waiver expenditure unless the labor is performed bya recognized repair technician. An official stamp is used to authenticaterepair receipts to prevent their reuse. Audit personnel perform oversightof waiver issuance. Oversight measures and procedures for the programhave been established by MDNR as part of the Procedures andSpecifications Manual (Attachment #9).

2. Basic I/M Program

a. MDNR has promulgated a rule for a waiver program that is incorporatedin the basic I/M program. This is authorized by section 307.366, RSMo(Attachment 1).

b. The State of Missouri issues waivers only when the requirements of theattached I/M rule and this paragraph are met. In the basic area, inspectionstation management are responsible for issuing waivers. Waiver issuancepersonnel review repair receipts to: verify that a minimum expenditureequal to or greater than $75 for 1971 through 1980 model year vehicles,$200 for 1981 and later model year vehicles has been made; verify thatonly repairs appropriate to the cause of the test failure have been claimed;and verify that repairs have actually been made by visually inspecting thevehicle. Waiver issuance personnel check the emissions test report for theodometer reading and model year and determine if the vehicle is eligiblefor warranty repairs, and require written denial of warranty coveragebefore issuing a waiver for a vehicle that is eligible for such repairs.Labor costs are not eligible towards the minimum waiver expenditureunless the labor is performed by a qualified or recognized repairtechnician. An official stamp is used to authenticate repair receipts toprevent their reuse. Audit personnel perform oversight of waiver issuance.Oversight measures and procedures for the program are established by

MDNR as part of the Procedures and Specifications Manual (Attachment#9).

3. The emissions test report for failed vehicles alerts motorists that they shouldpursue warranty repairs if the vehicle meets the age and mileage criteria.Emission inspectors provide motorists who fail the inspection with a copy ofliterature explaining warranty coverage. The EPA has published pamphletsexplaining the two (2) warranty provisions: (1) performance, and (2) design anddefect. The pamphlet “If Your Car Just Failed An Emission Test .. You May BeEntitled To Free Repairs” describes the performance warranty in detail. Thepamphlet “What You Should Know About Your Auto Emissions Warranty”describes the design and defect warranty. The performance warranty couldrequire the manufacturer to pay for all repairs necessary to pass the emission test.The design and defect warranty could require the manufacturer to pay for allrepairs to primary emission control parts, which are necessary to pass theemission test. Mileage and time constraints apply to both warranty provisions inthe Missouri I/M program.

L. Motorist Compliance Enforcement

Owners of vehicles subject to emissions inspections must present documentation of their vehiclepassing the emissions inspection or receiving a waiver in order to register their vehicle. InMissouri, registration is required upon purchase of a vehicle and then renewal of the registrationis required either annually or biennially. The MDOR requires an original current certificate ofemissions inspection no more than sixty (60) days old to register a subject motor vehicle, per theMissouri Driver’s Guide and 12 CSR 10-23.170. Hence, the St. Louis ozone nonattainment areamethod of compliance enforcement for the I/M program is registration denial.

There is no direct penalty to vehicle owners or drivers for not complying with vehicle I/Mrequirements. Penalties are, however, associated with owning and operating a vehicle withoutcurrent registration. Law enforcement officers ticket drivers for expired registration, evident byoutdated tabs on vehicle license plates. Also, there are late registration penalties assessed whenvehicles are registered after their registration has expired.

1. The legal authority in Attachment 1 includes the authority necessary to developand implement the enforcement element of the I/M program. The proceduresgoverning specific operation of this aspect of the program are contained inAttachment 9, part d). A penalty schedule for violations of these regulations isincluded.

2. The motorist compliance enforcement of the Missouri I/M program is based onregistration denial. Enhanced Emissions inspection frequency is biennial, wherehalf of the vehicle fleet is required to pass the inspection in order to obtainregistration renewal each year. For even-numbered registration years, all even-numbered model year subject vehicles must pass the inspection (and odd in odd).

Basic emissions inspection frequency is annual, where all of the vehicle fleet isrequired to pass the inspection in order to obtain registration renewal each year.The enforcement of this requirement is handled in cooperation with the MDORlicense offices in the affected counties. License personnel are prohibited fromissuing registration renewals and tag stickers unless an emission inspectioncertificate of compliance is presented. Verification of exempt vehicle status iscoordinated with the MDOR via quality assurance follow-ups. MDNR alsorequests confirmation of registration changes triggering an exemption. AMemorandum of Understanding (MOU) with MDOR is part of Attachment 3.

3. Enforcement of the requirement that vehicles receive a registration renewalannually is handled by state and local police agencies. If a vehicle owner is cited(ticketed) for an expired registration the owner is assessed a fine, which rangesfrom $20 to $60. Specific fines vary depending on the county the citation wasissued in. A separate fine, which ranges from $20 to $60, is assessed in thecovered counties for failure to display a valid inspection sticker.All remaining I/M program enforcement actions are the responsibility of MDNR.State law provides that any person who violates a requirement of sections 643.300to 643.355 or a rule promulgated to enforce sections 643.300 to 643.355 shall beguilty of either an infraction, a class C misdemeanor, or a class B misdemeanor(subsections 1-6 of section 643.355, RSMo). State law also provides that anyperson who violates any procedural requirement of sections 643.300 to 643.355shall be subject to a fine of not less than $120 (subsection 7 of section 643.355,RSMo).

4. The State of Missouri maintains the level of motorist enforcement necessary toensure a compliance rate of no less than ninety-six percent (96%) of subjectvehicles. The strategies described above and in Section G will ensure that theenforcement levels improve sufficiently to meet this compliance target. If it isdetermined as part of the required program evaluation that the I/M program is notmeeting the compliance rate committed to, measures will be taken to improvecompliance. MDNR uses the I/M program host computer to make a routinecomparison between the testing database and the registration database todetermine how many vehicles have evaded the emissions test requirement byrenewing vehicle registration without receiving a certificate of compliance orwaiver. MDNR uses parking lot surveys or roadside pullovers, by cooperatingwith state and local police agencies, to assess the compliance status of the in-usefleet. MDNR may develop a system to directly cross check the addresses claimedon the driver’s license and the vehicle registration to identify illegallyunregistered vehicles operating in the I/M area. If non-compliance is found to besignificant with this crosscheck, emission reduction credit losses will beaddressed.

M. Motorist Compliance Enforcement Program OversightUpon receipt of documentation of a vehicle passing the emission inspection or being waived, amotorist must present the documentation to the state license office for registration or registrationrenewal.

License offices are either operated by the state (called “branch” offices) or are under contract tothe state (called “fee” offices). The state agency that operates license offices and oversees thecontracted license offices is the MDOR. MDOR has more than one hundred fifty (150)contracted fee offices. The sample contract in Attachment 12 is from St. Louis County andcontains standardized text. Fee offices must adhere to all state guidance and rules per contractwith the state. Included in Attachment 12 is the guidance document that all branch and feeoffices receive regarding registering vehicles subject to the emission inspection requirement.The MDOR contract with the license offices contains procedures that serve to minimizeunauthorized activities at the offices and can eventually lead to the termination of contracts.The MDNR has a MOU with MDOR. The MOU stipulates that license clerks (state employeesor fee office employees) will verify I/M documents before issuing renewals. If clerks suspectfraudulent documents, no registration or renewal is issued and the offices notify the department.Per statute and MOU with the department, MDOR and/or the Highway Patrol will investigatesuspicion of counterfeit documents. The MDOR and/or the Highway Patrol will confiscatesuspect documents when possible and apply penalties or bring suit against persons involved infalsification of these I/M documents.State employees involved in oversight of document handling, or those that handle documentsthemselves are employed by MDNR, and the MDOR. These employees are subject to standardstate or department disciplinary actions for deviation from established requirements. Theseactions may include notation of deviations in performance appraisals. Less than satisfactoryperformance appraisals can lead to blockage of promotions, withholding of salary increases orwithholding of salary, and eventually can lead to termination.Contractor employees that deviate from standard requirements are also subject to appropriatepenalties. These include requirements to retrain and withhold salary and benefits, and can alsoultimately lead to termination.

1. The legal authority for the implementation of the I/M program is included inAttachment 1. This legislation includes the authority necessary to develop andimplement the enforcement program oversight element of the I/M program. Theprocedures establishing specific operation of this aspect of the program arecontained in Attachment 9, part e).

2. The MDNR enforcement program is based upon data analysis of the registrationand inspection databases to determine how many subject vehicles pass theinspection, are junked, are re-registered in outlying counties, or otherwisedisappear from the program. A follow-up survey of exempt vehicles andregistration changes triggering an exemption are conducted. Data analysis is alsoused to confirm that registration renewals are being properly issued at the licenseoffices. Cross checking of the two (2) databases is used to identify any vehicles,which, by any means, obtain registration without complying with the inspectionrequirement, and to otherwise assess program effectiveness. The data gatheredfrom these procedures is used as a supplement to the biennial program evaluation.If this data does not indicate a compliance rate of ninety six percent (96%), thencontingencies for greater compliance enforcement are presented as part of thereport.

3. The Procedures and Specifications Manual followed by personnel involved inenforcing and overseeing the I/M program is included in Attachment 9. This

manual details the procedures followed by MDNR and other State personnel andsupervisory personnel involved in I/M program enforcement, document handlingand processing. In the case of testing stations that issue program documents, afine equal to no less than the cost of the test fee plus the minimum waiverexpenditure is assessed for each such document which is missing or unaccountedfor.Per the MOU, the Missouri State Highway Patrol (MSHP) performsinvestigations of fraud and document counterfeiting upon request from MDNR.MDNR employs environmental specialists as part of the emissions inspectionenforcement program to conduct audits, report compliance and initiateenforcement actions. In addition, the affected motorists are required to presentthe MDOR branch and fee offices with current emissions inspection certificates ofcompliance when applying for a registration renewal, transfer, or issuance.Counterfeit certificates will most likely surface at the MDOR license and feeoffices. Per the MOU, MDOR personnel copy suspected counterfeit or illegalcertificates, turn over the suspected documents to the department and deny themotorist their registration. This is followed by investigations conducted byMDNR and MSHP personnel.

4. The State of Missouri encourages the EPA to conduct periodic audits of theState's I/M enforcement program.

N. Quality AssuranceThe contractor must assure the quality of the program per contract requirements. This assuranceis accomplished by auditing requirements for equipment, auditing of performance, and auditingof records. The contract requires several reports on test equipment and test performance onweekly, monthly, quarterly and annual schedules. The contract requires that MDNR has a rightto request an independent audit by a third party, paid by the contractor but with no corporate orother contractual ties to the contractor. This audit is per contract at RFP 3.2.15 and 10.7.5, andMethod of Performance 10.7.5n.State staff oversees and approve the reports described above. State staff oversees and approvesthe report of the independent audit as described above. State staff also conduct audits of stationsat routine intervals, at least annually per each inspection lane. State staff conduct overt audits oflane equipment and procedures, which include checks to verify that the equipment calibrationand preventive maintenance requirements are conducted on schedule.State staff conduct covert audits. These audits are done using state owned vehicles. The statevehicles used are unmarked, and have plain license plates (not official state vehicle plates).These vehicles are of various makes and a variety of model years. State staff may alter enginesor vehicle emission devices in order to cause excessive pollutant emissions from the vehicles.These vehicles are presented to the emission test stations, covertly, for an inspection. Contractorcompliance with state rules and contract terms are observed and noted. This includes, but notlimited to, notation of properly failing or passing the covert vehicles, notation of equipmentaccuracy, observance of lane inspector and station management actions and behavior, notation ofreceipt of proper documentation of the test and any informational materials required by rule orcontract.Improper procedures may violate state statute and rules, or the contract, or in many cases, both.If violations only pertain to state law, enforcement actions and remedies will be those authorized

under sections 643.300 – 643.355 or 307.366 RSMo. If improper procedures are in conflict withthe contract, sanctions per contract are applied including liquidated damages detailed at contractRFP section 9.11.

1. The legal authority for the implementation of the I/M program is included inAttachment 1. This legislation includes the authority necessary to develop andimplement the quality assurance element of the I/M program. The rulesgoverning specific operation of this aspect of the program are contained inAttachment 2.

2. Quality assurance procedures used by program auditors are included inAttachment 9, part f. Separate procedures are established for conducting overtand covert audits, which include sufficient record keeping requirements to supportthe imposition of enforcement actions based upon audit findings. All auditors arerequired to complete formal training.

3. The program will conduct at least two (2) overt audits per year, per test lane.Additional overt activity including activity aimed at suspected problem sites areconducted at MDNR's discretion. Overt audits include a check of documentsecurity, record keeping practices, licenses and required display information,observation and written evaluation of each inspector's ability to perform the testprocedure, and a quality control evaluation of test equipment. Test recordsreviewed electronically and by station to flag statistically inconsistent orimprobable results occurring either at individual stations or network-wide.

4. The program will conduct at least one (1) covert audit per year, for each I/Mstation inspector. Additional covert activity including activity aimed at suspectedproblem sites are conducted at MDNR's discretion. Covert vehicles aresometimes set to fail various aspects of the inspection so as to reflect the fullrange of technology and malfunction types, based upon procedures established inthe Procedures and Specifications Manual in Attachment 9. These proceduresrequire the remote observation of inspection facilities conducting 4,000 or moreinspections per year. The program employs at least one covert auditor per four(4) test sites, and rotates these auditors among testing areas to avoid detection.The identity of covert vehicles is concealed from the lane inspector bymanipulating the vehicle inspection database maintained by the contractor.

5. Program auditor training is conducted by I/M professional trainers or state auditsupervisors. Training of new auditing staff shall consist of at least forty (40)hours of combined training including classroom training, inspection lane training,repair bay training, and on-the-job field training under the direct supervision of atleast one (1) audit supervisor. Classroom training emphasizes administrative andenforcement procedures detailed in the auditor manual. Inspection lane and repairbay training emphasizes lane analyzer procedures, covert vehicle repair, andemissions system repair. On-the-job training includes overt and covert auditingfieldwork activities. All program auditors themselves are audited at least once peryear by MDNR supervisory personnel.

O. Enforcement Against Contractors, Stations, and InspectorsSince the I/M program is centralized with one (1) contractor responsible for operations, mostenforcement against the contractor, the contractor’s stations, and the contractor’s employees is

done through provisions of the contract. Most violations for improper testing, improperoperation of the program, and other key criteria result in liquidated damages. The compliancecriteria and associated penalties are detailed in the contract at RFP 9.11.

1. Liquidated damages are used in the case of systematic violations on the part of thecontractor. Additional penalties exist for the contractor for non-compliance with theprovisions of the contract. (See Attachment 4)

2. The contractor conducts its own hiring and firing. In addition, the contractordisciplines its employees for procedural and contractual violations independent of thedepartment’s efforts. In the case of inspector incompetence discovered by thedepartment, the inspector is required to be retrained and must successfullydemonstrate the ability to perform the test procedure prior to the restoration of testingprivileges. For cases of inspector violations resulting from factors other thanincompetence, the inspector shall be suspended from testing for a minimum of six (6)months, with such suspensions increasing with the severity and frequency ofviolation, leading ultimately to permanent dismissal. For cases of inspector violationsresulting from factors other than incompetence, the inspector shall be suspended fromtesting for a minimum of six (6) months, with such suspensions increasing with theseverity and frequency of violation, leading ultimately to permanent dismissal. Laneinspector retraining requirements are detailed in the contract at Methods ofPerformance 10.7.5.k.6. A requirement to terminate employees that improperly passvehicles is in the contract at RFP 9.11.12.

3. MDNR enforcement personnel investigate violations of the I/M rules and statutes.In addition to the enforcement provisions of the statutes, legal authority to enforce theprovisions of the I/M program is provided by the Missouri Air Conservation Law. Assuch, descriptions of administrative and judicial procedures and responsibilities areaddressed in the Air Law.

4. The penalty schedule in the operating contract applies for violations of contractprovisions. In the case of minor, ongoing violations MDNR may issue a Notice ofDeficiency (NOD) to the contractor, inspection facility or contractor employee. TheNOD details the nature, time of occurrence, and location of the violation as well as aresolution deadline. Failure to achieve compliance in the time and manner agreed toby both parties will result in MDNR pursuing contractual penalties.

P. Data Collection1. Attachment 9, part c), contains the equipment specifications that must be met by

all I/M testing equipment approved for use in the State of Missouri. Thespecifications in the contract between MDNR and the contractor provide datacollection requirements and record storage format. The information containedwithin each vehicle test report is such that it is possible to unambiguously tiespecific test results to a specific vehicle, test site, test lane, and inspector.

2. The State of Missouri gathers, maintains, summarizes, and reports the results ofall inspections, quality control checks performed on testing equipment and I/Mdocuments to the EP on an annual basis as described in Section Q below.

Q. Data Analysis and ReportingThe contract requires data reports for: 1) annual test data annually for the previous calendar yeardue by July, 2) annual quality assurance for the previous calendar year due by July, 3) annualquality control data for the previous calendar year due by July, 4) annual enforcement for theprevious calendar year due by July, 5) biennial report with: a.) changes to the program and b.)weaknesses in the program for the previous two calendar years, due by July. Report descriptionsare in RFP section 3. Because the emission I/M program started on April 5, 2000, the firstannual reports were due October 5, 2001, and the first biennial report was due October 5, 2002.Subsequent annual reports are due every July 15. Subsequent biennial reports are due everyother July 15.The state analyzes the reports for compliance with state law and contract requirements. Statestaff also analyzes the data for program effectiveness in reducing emissions from vehicles andadherence to consumer convenience requirements.

1. Beginning with the first full or partial I/M program calendar year and annuallythereafter the State of Missouri will report to the EPA summary data based uponprogram activities taking place from January1 through December 31 of theprevious calendar year. This report provides statistics for the testing program, thequality control program, the quality assurance program, and the enforcementprogram. The State will address all of the data elements listed in 40 CFR 51.366.

2. Beginning after the first full or partial I/M program calendar year and bienniallythereafter the State of Missouri will report to the EPA on all changes made in theprogram design, funding, personnel levels, procedures, regulations, and legalauthority, and shall supply a detailed discussion of the impact of such changesupon the program. This report shall also detail and discuss any weaknesses orproblems discovered in the program over the previous two (2) year period, as wellas the steps that were taken to address the problems, the result of correctiveactions, and any future efforts planned.

R. Inspector Training and Repair Mechanic TrainingInspectors are employees of the contractor. The contract at RFP 3.1.11, 4.4.4, and 4.4.5 requiresinspectors to be trained in the test procedures and Missouri requirements by the contractor. Thecontract at RFP 4.5 and 10.7.5, and Discussions 4.5 requires plans for the training. Contractorstation managers are trained on station management skills and on the waiver procedure.Only inspection services are allowed. Repairs to vehicles at emission test stations or byinspectors are prohibited by statute and the contract (643.310 4. (6) RSMo and RFP 1.6) –Repairs to vehicles that fail the I/M inspections may be done offsite by the owner, by any repairtechnician, or by a “recognized qualified repair technician.” Only the labor cost of recognizedqualified repair technicians count toward the qualifying waiver expenditure. Recognized repairtechnicians are defined by state rule 10 CSR 10-5.380. Qualified repair technicians are definedby state rule 10 CSR 10-5.375. These technicians are employees of independent businesses, notassociated with either the state or the I/M contractor. Training is paid by the technician or hisemployer and is offered by independent schools or training providers. The department setscriteria and approves courses to meet the requirements of rule definition of recognized repairtechnicians.

1. The contractor conducts inspector training and certification examinations. Thedepartment approves both the inspector training courses and the exam. Inspectorsmust be re-examined every two (2) years. Inspectors must receive greater than 80percent (80%)on the exam to conduct inspections per Discussions in Response tothe RFP binder 4.5 and Method of Performance binder 10.7.5.k. The curriculaincludes, but is not limited to:a. General I/M program orientation

i. Missouri I/M historyii. Purpose and goal of I/Miii. Contribution of the automobile to air pollutioniv. Missouri regulations and lawsv. Vehicle emissions and standards

b. Station operations and proceduresi. State of Missouri I/M staff organizationii. The contractor’s staff organizationiii. I/M inspection networkiv. I/M inspection station organizationv. Lane overviewvi. Equipment overview

c. Customer service, safety, complaint handling, and public relationsd. Security of the inspection station

2. Only the inspection station management may issue waivers. Their trainingincludes the passing training requirements for the inspectors and the followingadditional curricula:a. Station managementb. Human resourcesc. Lane operationsd. Customer relationse. Waiver investigation

3. MDNR monitors station management and inspector training. A quality assuranceofficer on a biennial basis evaluates station management and inspectorcompetence.

4. MDNR worked with community colleges and vocational schools and privatetraining providers in order to ensure adequate repair technician trainingopportunities existed prior to the beginning of enhanced I/M testing. MDNRpromotes, coordinates, monitors, and evaluates the training program for emissionrepair technicians. Local community colleges and vocational schools provide thesetting for repair technician training. MDNR recommends repair techniciansmeet recognized repair technician requirements included in the rule (Attachment2).

5. State recognized repair technicians are defined by state rule 10 CSR 10-5.380. Arecognized repair technician is any person who:a. Is professionally engaged full-time in vehicle repair or employed by an

ongoing business whose purpose is vehicle repair. A Recognized Repair

Technician may only be recognized by the department at one place ofemployment.

b. Has valid certifications in National Institute for Automotive ServiceExcellence (ASE) in Electrical Systems (A6), Engine Performance (A8),and Advanced Engine Performance Specialist (L1) that have not expired.

c. Has satisfactorily completed a department approved course covering:i. Air quality information – vehicle emissions and ozone formation,

St. Louis’ air quality situation, and Federal requirements for ozonereduction

ii. The St. Louis area I/M program – overview of I/M program,waivers, forms used in I/M program, and overview of Illinois I/Mprogram

iii. Recalls and warrantiesiv. Repair technician hotlines and informational materialv. Inspection station proceduresvi. IM240 drive trace analysis and emission failure diagnosing

d. Has satisfactorily completed at least one (1) four (4)-hour continuingeducation course per calendar year offered by the department.

S. Public Information and Consumer ProtectionThe State of Missouri conducts an ongoing public information and consumer protection plan.The plan is comprehensive and includes a substantial minimum expenditure, by year, by thecontractor. For details see the contract at RFP section 8 and Methods of Performance 10.7.7.The public information program began six (6) months prior to the start of the program andincluded information on the upcoming changes in the program, how the consumer will beaffected, and the requirements of federal and state law. MDNR works closely with the I/Mcontractor to ensure the public is informed on an ongoing basis of I/M related issues. The I/Mcontractor is responsible for developing the public information campaign, subject to MDNRapproval. The I/M contractor is required to spend a specific portion of the fees for publicinformation. I/M facilities are required to provide motorists with information regarding how toobtain warranty repairs, components responsible for the test failure to the extent possible, and theresults of an ongoing survey of the service provided at local repair facilities. The consumerprotection program also assists motorists in obtaining repairs covered under emissions warranty.MDNR follows-up and responds to complaints made by the public and others in the community.Customers may challenge the results of their inspection or report inspector fraud to MDNR. Thecustomer may bring their motor vehicle to the Quality Assurance Facility to have their vehiclere-inspected. The customer will also be given a phone number and form to issue complaints offraud to MDNR.Motorists whose vehicles fail are given information on vehicle manufacturers’ warranties, ifapplicable, by the contractor per the contract at RFP 8.1.4. Since the St. Louis area I/M programis an official local emissions inspection program, recognized by the federal government, vehiclemanufacturers’ dealerships must honor warranties based on performance. If a vehicle is withinfederally set mileage and age limits and the vehicle fails the St. Louis area I/M inspection,warranties must be honored or a written explanation for refusing to honor a warranty must begiven.

MDNR has required the contractor to include a whistle blower protection component, designedto keep the names of employees that report violations of the law confidential, within the I/Mconsumer protection program. The contractor is using the Partners Against Loss (PAL) programand is using an outside and independent agency to provide their employees with twenty-four (24)hour assistance. The agency acts as a liaison between the employee and the contractor.All Missouri State employees are protected from repercussions from reporting deviations fromstate law within state government. Section 105.055 RSMo provides this “whistleblowers”protection.

T. Improving Repair EffectivenessAs described above, repair technician training is required for state recognized repair technicians.Such training is not provided by the state. Non-profit and for-profit schools and independenttrainers provide this training. The department reviews and approves courses per rule definitionof recognized repair technician. The department sets criteria for course curricula and anadequate amount of class hours to adequately cover the curricula topics. Curricula include, butare not limited to, the basics of air pollutant formation, training on consequences of emissionsfrom vehicles, overview of federal air quality requirements, review of Missouri I/M statutes andrules, overview of the contractor requirements for vehicle testing, study of the test procedure,introduction to diagnosis of the causes of emission test failures, requirements and responsibilitiesof being a state recognized repair technician.Non-profit schools in the St. Louis area include post-high school technical schools andcommunity colleges that offer automotive repair courses for in-service technicians. St. Louisalso has at least one (1) for-profit college that offers night courses for in-service technicians.Independent trainers are located in St. Louis or may come from other states to provide training.These include companies that only provide training and textbooks or training materials,companies that also provide repair parts and sales, and companies that also provide repair toolsor diagnostic equipment.

1. The State of Missouri meets the technical assistance requirements of 40 CFRSection 51.369(a). MDNR requires the contractor to provide a hot-line service toanswer questions from the repair industry. MDNR provides the repair industrywith information and assistance related to vehicle inspection diagnosis and repairvia a quarterly newsletter. Both the newsletter and the hot-line service arecoordinated with the contractor and are funded using the contractor’s portion ofthe test fee. See the public information language in Attachment 4.

2. The repair effectiveness performance of repair facilities is tracked. The State ofMissouri provides the information listed in 40 CFR Section 51.369(b) oralternative information conveying similar information on the ability of repairfacilities to provide effective and convenient repair to the public at the time ofinitial failure. The contractor is required to provide this repair facilityeffectiveness information, which is tracked by computer compilation of data fromcompleted repair forms, to the motorist. A completed repair form is required as aprerequisite for reinspections and waiver applications.

U. Compliance with Recall NoticesThe enhanced I/M rule, included in Attachment 2, requires vehicle owners in the enhanced I/Marea to comply with recall notices in order to pass the emissions inspection. Vehicle owners who

have obtained recall repairs but remain on the unresolved recall list can complete the inspectionprocess, if they present a recall repair completion form from the dealership to the inspectors atthe contractor’s emission test stations.Contract requirements for outstanding recall checks and requirements for the contractor tomaintain a recall database are at RFP 3.3.5 and Method of Performance 10.7.5.g.1.The State of Missouri has submitted the annual report required by 40 CFR Section 51.370(c).

V. On-road TestingWhile the contractor conducts on-road RapidScreen testing for clean screening, the contractoralso conducts RapidScreen testing for clean screening to provide information about theperformance of in-use vehicles. This on-road testing is required by contract at RFP 3.1.13 andMethod of Performance 10.7.5.s.

1. On-road testing is conducted in the I/M program area of the State of Missouri.The legal authority for this testing is contained in the I/M legislation inAttachment 1. The results and conclusions from these tests are presented in theannual reports made available to the public, the legislature, and EPA.

2. The on-road test is conducted via portable on-road analytical equipmentmeasurements of HC, CO, CO2, and NOx or other on-road testing. A minimum of0.5 percent of the vehicle fleet covered by the enhanced I/M program receives aremote sensing test or other on-road test each year.

W. State Implementation Plan SubmissionsThe following is a schedule implementing the enhanced I/M program in the St. Louis ozonenonattainment area:1. Passage of legal authority May 13, 19982. Signature of Governor Jun. 03, 19983. Adoption of I/M rule by MACC Aug. 27, 19994. Issuance of RFP Oct. 26, 19985. Bid conference Nov. 13, 19986. RFP bids due Jan. 07, 19997. Contract awarded Feb. 24, 19998. Complete station construction Apr. 05, 20009. Complete inspectors training Apr. 05, 200010. Complete station acceptance testing Apr. 05, 200011. All I/M program requirements go into effect Apr. 05, 2000

(Start of Mandatory Testing)12. Phase-in cutpoints take effect Apr. 05, 200013. Program cutpoints take effect Feb. 04, 200214. 2000 annual reports completed Jul. 15, 200115. 2000 - 2001 biennial reports completed Jul. 15, 200216. 2002 annual reports completed Jul. 15, 2003